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AMEND16ROBERTWIRENGARD v. COMMISSIONER

Dkt. No. 18437-03X.

89 T.C.M. 785 (2005)

T.C. Memo. 2005-30

Amend16robertwirengard v. Commissioner.

United States Tax Court.

February 22, 2005.

Attorney(s) appearing for the Case

R.O. Wirengard (an officer), for petitioner.

Helen F. Rogers, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

In a final adverse determination letter, respondent determined that petitioner did not qualify for exemption from Federal income taxation pursuant to section 501(a) as an organization described in section 501(c)(3).1 Having exhausted its administrative remedies, petitioner challenged respondent's determination by timely filing a petition for a declaratory judgment pursuant to section 7428(a)....

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